Dodd-Frank Section 1502

Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (enacted July 21, 2010) is the U.S. legislative provision requiring SEC-registered issuers that manufacture or contract to manufacture products containing tin, tantalum, tungsten, or gold (3TG) — where such minerals are necessary to the product’s functionality or production — to disclose annually whether those minerals originated in the DRC or adjoining countries. Section 1502 added Section 13(p) to the Securities Exchange Act of 1934 and directed the SEC to promulgate implementing rules.

Dodd-Frank Wall Street Reform and Consumer Protection Act, Pub. L. 111-203, § 1502 (July 21, 2010); Exchange Act Section 13(p); SEC Rule 13p-1.

Section 1502 is the statutory foundation of U.S. conflict minerals compliance. It applies to SEC-registered manufacturers, not to private companies or non-manufacturers. In 2025–2026, there is ongoing political debate about the rule’s effectiveness and cost, with some SEC commissioners questioning its continuation. However, as of April 2026, the rule remains in force and Form SD filings are required annually by May 31. Companies should monitor SEC announcements for any changes in enforcement posture.

A publicly traded U.S. medical device company manufactures products containing gold in sensors and tungsten in radiation shielding. Both minerals are necessary to product functionality, triggering Section 1502 obligations. The company conducts an annual RCOI, collects CMRT data, and files Form SD by May 31 each year.